Motrya Olha Mayewsky, Petitioner
T.C.
Opinion
S;4' --f 0)tj T .C . Memo . 2008-28 6 UNITED STATES TAX COUR T MOTRYA OLHA MAYEWSKY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 10820-07 .
Filed December 22, 2008 .
Motrya Olha Mayewsky, pro se .
Kelly R . Morrison-Lee and Scott A . Hovey , for respondent .
MEMORANDUM FINDINGS OF FACT AND OPINIO N FOLEY, Judge : The issue for decision is whether petitioner is entitled to deduct amounts claimed as theft and casualty losses and as miscellaneous itemized expenses relating to 2003, 2004, and 2005 .
ED DEC 2 2 2008 FINDINGS OF FAC T Petitioner timely filed her returns relating to 2003, 2004, and 2005 . On each return, petitioner claimed a $10 million theft and casualty loss relating to a stamp collection, U .S . savings bonds, and other personal property . On February 14, 2007, respondent issued petitioner a notice of deficiency relating to 2003, 2004, and 2005, in which respondent disallowed itemized deductions of $10,012,633, $9,997,469, and $9,994,315,1 respectively, and determined deficiencies of $6,129, $4,469, and $5,069, respectively . On May 15, 2007, petitioner, while residing in Virginia, filed her petition with this Court .
OPINION
Section 1652 allows a deduction for casualty and theft losses sustained during the taxable year and not compensated for by insurance or otherwise . Sec . 165(a), (c)(3) . On the returns relating to the years in issue, petitioner deducted miscellaneous itemized expenses and exorbitant casualty and theft losses .
Petitioner contends that her savings bonds, stamp collection, and other personal valuables were stolen and that her home was damaged by a flood . There is no credible evidence, however ,
supporting petitioner's contentions and claimed deductions .3 In fact, petitioner acknowledged that "My putting $10 million dollars each year from 2003-2205 [sic] was just an estimated amount" . Accordingly, we sustain respondent's determinations .
Contentions we have not addressed are irrelevant, moot, or meritless .
To reflect the foregoing, Decision will be entere d for respondent .
- These amounts were adjusted for computational limitations based on petitioner's adjusted gross income .
- Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the years in issue .
- Pursuant to sec . 7491(a), petitioner has the burden of proof with respect to the claimed deductions because she failed to introduce credible evidence .